Appeal Narrative

City of Glendale — Regular Meeting (2026-03-24)

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Project Narrative – Conditional Use Permit (CUP) Appeal 
T&T Investment 2 LLC 
15410 N. 67th Ave., Suites 13–14 
Glendale, AZ 85306 
February 4, 2026 (Updated February 22, 2026) 
Re: CUP Appeal – Retail Smoke and Vape Shop (Suites 13–14) 
Case No.: CUP25-15 
To: Planning Staff and City Council 
Dear Planning Staff and Council Members 
My name is M. Ryan Hurley attorney with Litix Legal, and I am the authorized representative for Talal 
Almotawaa and T&T Investment 2 LLC (“Applicant”). We respectfully submit this project narrative in 
support of this appeal of the denial of a Conditional Use Permit (“CUP”) application for a retail smoke and 
vape shop at 15410 N. 67th Avenue, Suites 13–14, Glendale, Arizona 85306 (the “Site”). 
 
1. Applicant, Site, and Project Overview 
Applicant: T&T Investment 2 LLC 
Authorized Representative: M. Ryan Hurley, Litix Legal 
Property Owner: Nass 3 Property LLC 
Site Address: 15410 N. 67th Ave., Suites 13–14, Glendale, AZ 85306 
 
The Site is located in an established commercial corridor on the west side of 67th Avenue, just north of 
Greenway Road. It is part of an existing retail center with direct access to 67th Avenue and Greenway Road, 
existing circulation patterns, shared parking, and visibility from the main roadway. 
The proposal is to repurpose an existing commercial tenant space (Suites 13–14) for a retail-only smoke and 
vape shop serving adult customers in a controlled, age-restricted environment. No new building, no change in 
access points, and no changes beyond typical tenant improvements. 
The Applicant is an experienced retail operator with numerous locations in the City of Phoenix that have 
been operating without complaints or incidents for several years with perfect 5.0-star Google ratings from 
thousands of reviews.  In addition, the Applicant, is a valued member of the local community who gives back 
by offering free meals to those who are in need, particularly at Thanksgiving.   
Because this is his first business venture in the City of Glendale, he was unfamiliar with the City’s zoning 
and licensing requirements which differ significantly from those in Phoenix.  The City of Phoenix does not 
require a business license nor a use permit for this type of business.  As such, he was initially unaware of 
both requirements.  However immediately upon learning of the City’s requirements he has been diligently 
pursuing compliance.   
During the Planning Commission hearing it appears the Commission was under the impression that the 
Applicant willfully ignored the City’s requirements and operated without even obtaining a transaction 
Received
02/23/2026

privilege tax license.
 
This appears to have been a basis for
 
the Commission’s
 
denial of the
 
CUP,
 
but it was 
based on a
 
mistake of fact.
 
The
 
Applicant
 
indeed
 
applied
 
for and
 
obtained a TPT license prior to opening,
and in fact emailed
 
City staff inquiring
 
about zoning compliance
 
and
 
submitting
 
a
 
business
 
license 
application
 
at
 
the
 
same time.
 
He
 
only learned of the CUP requirement
 
when his business license
 
application
was denied
 
20 days later.
The bottom line is that this
 
Applicant
 
has
 
been
 
pursuing compliance
 
in good faith from the beginning.  The 
Commission’s denial
 
of the CUP was
 
based on this
 
mistake of
 
fact,
 
and therefore
 
this appeal is justified and
the CUP should be approved.
2. Proposed Use (Retail-Only; Adult Customers; No On-Site 
Consumption)
The business will provide
 
retail sales
 
of tobacco products (as permitted by law), vape devices, vape 
accessories, and related merchandise, in compliance with
 
all federal, state, and local regulations.
This CUP request is for a
 
retail storefront only
 
and
 
does not
 
include:
• Any
 
lounge
 
or consumption area
• Any
 
on-site consumption
 
or sampling
• Any entertainment use or event-based activity
The intent is to operate as a modern, clean, professional retail tenant that complements surrounding 
commercial businesses in the center.
3. Hours, Staffing, and Day-to-Day Operations
Proposed hours of operation:
 
8:00 a.m. to 12:00 midnight, seven (7) days per week.
Staffing:
 
The shop will typically be staffed by
 
two (2) employees
 
who provide customer service, inventory 
management, and store operations. A manager or responsible person will be reachable during all operating 
hours to respond to issues
 
check ID’s
 
and ensure compliance
 
with all laws and regulations.
Deliveries:
 
Deliveries will occur
 
during off-peak hours when feasible
 
and will use existing circulation and 
parking/loading practices within the center. Deliveries will not obstruct drive aisles or pedestrian access.
4. Operational Commitments (Compliance and Youth-Access 
Prevention)
The Applicant commits to operating under strict, documented procedures intended to prevent youth access,
deter nuisance activity, and support safe, compliant operation.
4.1 Universal ID Checks and 21+ Compliance
• The business will be
 
21+ for age-restricted product sales, consistent with federal and Arizona law.
• The business will implement
 
universal ID checks: every customer, every sale, every time, with
 
no 
exceptions.
• ID verification will be performed by visual inspection of a government-issued photo ID and, if

implemented/required, an electronic ID verification system. 
• Employees will refuse sales if the customer cannot present valid ID, the ID appears altered or 
fraudulent, or a straw purchase is suspected. 
4.2 Employee Training 
All employees will complete training on age verification and legal compliance, identifying fake IDs and 
straw purchases, refusal and de-escalation protocols, and store safety and emergency procedures.  Training 
will occur before independent shift work, upon hire, and at least annually thereafter. 
4.3 No THC/Marijuana; No Vending Machines 
The business will not sell marijuana, THC, or cannabis products, and this CUP request does not seek any 
approval related to such products. No vending machines will be used for any age-restricted products. 
4.4 No On-Site Consumption / No Lounge 
No on-site consumption, sampling, or “vape lounge” activity will be permitted, and the store will not provide 
seating or an area intended for product use on-site. 
5. Security Measures (Crime Prevention and Site Management) 
The Applicant will implement security measures to deter nuisance activity, support safe operations, and assist 
law enforcement when needed.  These measures will include security cameras covering entry/exit points, 
point-of-sale area, and sales floor and exterior storefront area.  Video recordings will be retained for at least 
30 days and made available to law enforcement upon lawful request.  Further, the Applicant will maintain a 
monitored alarm system, and adequate exterior and entry lighting to deter loitering and promote visibility. 
6. Signage and Marketing Restrictions 
The Applicant acknowledges community sensitivity around this use and agrees to operate with restrained, 
code-compliant marketing consistent with professional retail storefront.  All signage will comply with City 
sign standards and applicable shopping center/landlord requirements.  There will be no exterior product 
displays, and no window signage depicting minors, cartoons, or youth-oriented imagery. 
7. Tenant Improvements and Site Impacts 
The project scope consists of only interior improvements to the approximately 2500 SF suite, including new 
shelving, display fixtures, and counter layouts, the Site will otherwise remain unchanged and compliant with 
the retail center’s current layout and City regulations. 
8. Compatibility, Traffic, and Parking 
The Site is within a functioning commercial retail center intended to serve the surrounding community with a 
variety of retail services. The proposed use is compatible with the area because it: 
• operates entirely indoors within an existing tenant space; 
• does not generate industrial impacts, outdoor activity, odor or event-based traffic; 
• is managed as a controlled, age-restricted retail environment with enhanced compliance and security 
measures; and

• uses existing shared parking and existing driveway access without modifications. 
Traffic and Parking: The business is expected to create customer turnover consistent with typical small-to-
medium retail uses. Parking will remain shared and consistent with the center’s established operation; no 
changes to ingress/egress or circulation are proposed. 
9. Applicant-Offered Conditions of Approval  
To support a clear, enforceable approval framework, the Applicant voluntarily agrees that the CUP may 
include conditions substantially similar to the following: 
1. 
Retail-Only / No Lounge: The use shall be limited to retail sales; no on-site consumption, 
sampling, or lounge use is permitted. 
2. 
21+ Compliance: The business shall comply with all federal and state age-restriction laws and 
shall not sell age-restricted products to any person under 21. 
3. 
Universal ID Checks: Government-issued photo ID shall be checked for every customer, every 
sale, every time, with no exceptions. 
4. 
Electronic Verification: Implement and use an electronic ID verification system  for ID 
verification. 
5. 
Training: Employees must complete compliance training before independent shifts and at least 
annually; training records must be maintained on-site. 
6. 
No THC/Marijuana: No marijuana/THC/cannabis products may be sold on-site (this CUP does 
not authorize such sales). 
7. 
Security Cameras: Maintain camera coverage of entries/exits, POS, sales floor, and storefront 
exterior; retain recordings for at least 30 days. 
8.    Alarm System: Maintain a monitored intrusion alarm system. 
9. 
Lighting: Maintain adequate exterior and entry lighting consistent with City requirements and 
shopping center standards. 
10. 
No Loitering / Litter: Post and enforce no-loitering signage; perform daily litter sweeps of the 
storefront frontage and immediate adjacent area. 
11. 
Signage Restrictions: All signage must comply with City code; no youth-oriented window 
imagery; no exterior product displays; no flashing/strobing lighting. 
12. 
Deliveries: Schedule deliveries during off-peak hours when feasible and ensure deliveries do not 
block drive aisles or pedestrian access. 
13. 
Hours: Hours shall be limited to 8:00 a.m. to 12:00 midnight, or such reduced hours as imposed 
by the approval

12. CUP Criteria  
The Applicant respectfully submits that, with the commitments and conditions stated above, the CUP can 
meet applicable approval criteria, including: 
• Consistency with the General Plan and zoning intent: The Site is located in an established 
commercial corridor and existing retail center where retail uses are anticipated and appropriate. The 
project reuses an existing tenant space. 
• Compatibility and harmony with surrounding uses: The use is indoor, retail-only, and managed 
with nuisance-prevention, signage restrictions, and security measures that promote compatibility with 
adjacent tenants and nearby properties. 
• Protection of public health, safety, and welfare: The Applicant’s universal ID policy, training, no-
consumption rule, and security and signage commitments reduce risk and support compliance and 
public safety. 
• Adequate access, utilities, and parking: Existing access, circulation, utilities, and shared parking 
already serve the retail center; no new infrastructure is required. 
• No undue traffic, parking, or nuisance impacts: The use is consistent with normal retail activity 
and is not expected to create traffic or parking impacts beyond ordinary retail turnover; no exterior 
noise, odors, or emissions are expected beyond normal retail activity. 
 
13. Conclusion and Request 
For the reasons stated above, the Applicant respectfully requests that the Council grant the appeal and 
approve the CUP, subject to reasonable conditions consistent with the operational commitments and 
Applicant-offered conditions outlined in this revised narrative. 
We appreciate your time and consideration and look forward to working with the City of Glendale 
throughout the review and approval process. 
Sincerely, 
 
M. Ryan Hurley on behalf of: 
Talal Almotawaa 
T&T Investment 2 LLC